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Ludwig Tribunal Petition Letter.pdf

Rachel Ludwig Petitioner V Township Of Oronoko Respondent · 26-000619-TT

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Page 1

​Michigan Tax Tribunal Petition​

​Small Claims Division – Residential Property​

​Petitioner:​​Mark Ludwig and Rachel Ludwig (f.k.a.​​Mataitis)​

​Mailing Address:​​11305 Burgoyne Rd, Berrien Springs,​​MI 49103​

​Parcel ID​: 15-0033-0001-01-3​

​County​: Berrien​

​Tax Years at Issue:​​2026 (primary), and 2021–2025​​for correction and refund​

​Respondent​: Oronoko Charter Township​

​Statement of Appeal​

​We respectfully appeal the Board of Review’s partial reduction of our 2026 SEV to $350,000. At​

​the March 12, 2026 hearing, we requested a reduction to $275,000 based on recent RUR2​

​comparable sales and documented record-card errors. During the hearing, the Board asked for​

​the original appraisal, noting it would be helpful in making their decision. We promptly obtained​

​the appraisal from our mortgage company and provided a copy to the Board.​

​After carefully reviewing the appraisal ourselves, we discovered that the original SEV, set by the​

​assessor at the time (Linda Schadler), did not align with the appraisal. The 2018 appraisal,​

​which was subject to completion per plans and specifications, valued the completed home at​

​$400,000 true cash value​, implying an SEV of approximately​​$200,000​. However, the assessor​

​set it at​​$302,300​​— significantly higher than the value supported by the appraisal. The Board​

​ultimately granted only a partial reduction.​

​In light of this discovery, we are now respectfully requesting a reduction to​​$225,000 SEV​. This​

​professional appraisal, combined with the documented record-card errors and the mathematical​

​impossibility of the capped value rising as high as it did under Proposal A, demonstrates that the​

​overassessment was systemic and long-standing. We also respectfully request review and​

​correction of prior years 2021–2025 for refunds.​

​Key Facts and Evidence​

​1.​ ​Original Professional Appraisal​

​At the time of completion (~2018-2021), a licensed appraisal valued the property at​

​$400,000 true cash value. This should have produced an SEV of approximately​

​$200,000. Instead, the assessor set the 2021 SEV at $302,300, and the​

​overassessment has compounded since.​

​2.​ ​Record Card Errors (inflating value from the start)​

​○​ ​Basement listed as 1,700 sq ft finished recreation space (actual: completely​

​unfinished except ~400 sq ft with drywall hung only for code compliance).​

​○​ ​Walk-out doors listed as 2 (actual: only 1 set of French doors).​

​○​ ​Jacuzzi tub replacement listed as 1 (actual: none).​

​○​ ​Garbage disposal listed as 1 (actual: none).​

​3.​ ​Capped Value Could Not Have Increased This Much​​Even​​applying the maximum​

​allowed Proposal A caps each year, a correct starting SEV of $200,000 in 2021 would​

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​have reached only $234,608 by 2025 (and approximately $240,902 by 2026). However,​

​our actual capped TV reached $364,537. See Exhibit A below.​

​4.​ ​Recent Comparable Sales​​(All RUR2 Neighborhood) Seven recent arms-length sales​

​in the same RUR2 neighborhood (2023–2026) support a significantly lower value. Full​

​comp table attached.​

​Exhibit A: Proposal A Capped Value Calculation and Overpayment Analysis​

​Table 1: Official Inflation Multipliers and Actual Caps Applied​

​Year (for taxes in)​

​Official Inflation Multiplier​

​Actual % Cap Applied to TV​

​2022​

​1.033​

​3.3%​

​2023​

​1.050​

​5.0%​

​2024​

​1.050​

​5.0%​

​2025​

​1.031​

​3.1%​

​2026​

​1.027​

​2.7%​

​Table 2: Correct Capped Value vs. Actual (Proposal A Cap Progression)​

​(Starting with correct SEV of $200,000 in 2021)​

​Year​

​Correct​

​Capped TV​

​(should​

​have been)​

​Actual​

​Capped TV​

​Actual SEV​

​Assigned​

​Correct​

​Taxes​

​(should​

​have been)​

​Actual​

​Taxes Paid​

​Annual​

​Overpayment​

​2021​

​$200,000​

​$302,300​

​$302,300​

​~$5,067​

​$7,991.25​

​~$2,924​

​2022​

​$206,600​

​$312,275​

​$320,900​

​~$5,235​

​$8,271.06​

​~$3,036​

​2023​

​$216,930​

​$327,888​

​$378,300​

​~$5,497​

​$8,483.77​

​~$2,986​

​2024​

​$227,777​

​$344,282​

​$414,700​

​~$5,772​

​$8,967.01​

​~$3,195​

​2025​

​$234,608​

​$354,954​

​$422,900​

​~$5,945​

​$9,163.71​

​~$3,218​

​2026​

​(tentative)​

​$240,902​

​(tentative)​

​$364,537​

​(tentative)​

​$465,000​

​(tentative)​

​~$6,104​

​(tentative)​

​TBD​

​TBD​

​Total estimated overpayment 2021–2025: ~$15,360​

​Note on Calculation:​​Correct taxes were calculated using the official homestead millage rate of​

​25.3361 mills published by the Michigan Department of Treasury and Berrien County for​

​Oronoko Charter Township / Berrien Springs Public Schools. This rate has been consistent in​

​recent years. Actual taxes paid are taken directly from our tax bills.​

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​Requested Relief​

​●​ ​Reduce the 2026 SEV to​​$225,000​​(TV resets to $225,000),​​justified by the original​

​appraisal and current RUR2 comps.​

​●​ ​Review and correct prior years 2021–2025 for refunds due to the same errors, original​

​appraisal misalignment, and compounded overassessment.​

​●​ ​Any other relief the Tribunal deems appropriate, including interest on refunds.​

​Attachments​:​

​●​ ​Original $400k appraisal​

​●​ ​BS&A property record card pages with errors highlighted​

​●​ ​Comparable sales table​

​●​ ​BOR decision form​

​Thank you for your time and consideration.​

​Sincerely,​

​Mark and Rachel Ludwig​

​313-717-1948​

​ludwig.rachel.n@gmail.com​

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